https://www.taxtmi.com/caselaws?id=466178 A trust formed under the SARFAESI framework for acquisition and reconstruction of stressed financial assets was treated as a valid revocable trust and not an association of persons. The Tribunal followed its co-ordinate bench rulings on similar ARCIL trusts, holding that common identity between contributors and beneficiaries does not invalidate the trust under the Indian Trust Act, 1882 and does not, by itself, create an AOP. It also found the contribution arrangement revocable within sections 61 to 63 of the Income-tax Act, 1961, and noted that the security receipt holders' shares were known from inception, so the trust was not indeterminate. Income was therefore assessable in the hands of the beneficiaries. en-us Fri, 07 Jun 2024 00:00:00 +0530 Wed, 28 Jan 2026 13:57:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466178 A trust formed under the SARFAESI framework for acquisition and reconstruction of stressed financial assets was treated as a valid revocable trust and not an association of persons. The Tribunal followed its co-ordinate bench rulings on similar ARCIL trusts, holding that common identity between contributors and beneficiaries does not invalidate the trust under the Indian Trust Act, 1882 and does not, by itself, create an AOP. It also found the contribution arrangement revocable within sections 61 to 63 of the Income-tax Act, 1961, and noted that the security receipt holders' shares were known from inception, so the trust was not indeterminate. Income was therefore assessable in the hands of the beneficiaries. Case-Laws Income Tax Fri, 07 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466178